1993 Center for Auto Safety Petition to Upgrade FMVSS 301


December 8, 1993

The Honorable Federico Pena
Department of Transportation (DOT)
400 Seventh Street SW
Washington DC 20590

Dear Secretary Pena:

The Center for Auto Safety (CAS) has completed the enclosed analysis
of General Motors 1973-87 pickup truck fires that show the cost to be
$2.0 billion with an additional $800 million expected in the future unless
the trucks are recalled. The analysis was based on a sophisticated computer
model and database developed for the Consumer Product Safety Commission
and the Federal Highway Safety Administration by the National Public Services
Research Institute. If half the deaths reported by National Highway Traffic
Safety Administration (NHTSA) in its 1990 evaluation of Federal Motor
Vehicle Safety Standard (FMVSS) 301 are due to fire, the annual cost of
vehicle fires in the United States is approximately $4 billion.

The 1990 NHTSA evaluation of FMVSS 301 failed to show any reduction in
vehicle crash fire fatalities due to the standard. Overall, deaths in
crash fires increased from 1,300 in 1975 to 1,800 in 1988 while overall
traffic deaths were decreasing. The enormous cost of crash fires to the
nation and the admitted ineffectiveness of FMVSS 301 makes revision of
this safety standard a priority.

The Center for Auto Safety calls on NHTSA to initiate rulemaking as soon
as possible to upgrade FMVSS 301 to provide a level of performance such
that "fuel leaks, should not occur in collisions which produce occupant
impact forces below the threshold of fatality" — i.e., if you survive
the crash forces, you should not be burned by fires from fuel leaks. Since
crash protection technology in new vehicles today enables occupants to
survive 45 mph frontal fixed barrier crashes, 45 mph side moving barrier
and 45 mph fixed rear barrier, FMVSS 301 should be amended to require
no fuel leakage at these impact velocities or 45 mph in the near term.
As crashworthiness protection improves in the future, FMVSS 301 should
be further amended to provide for no fuel leakage in the specified crash
modes at 55 mph.

Thank your for your attention to this vehicle safety need.


Clarence M. Ditlow
Executive Director

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